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HomeMy WebLinkAboutDRC-2015-002395 - 0901a06880529ea0/ ) Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 ENERGYFUELS www.energyfuels.com May 6,2015 VIA PDF AND OVERNIGHT DELIVERY DRC-2015-002395 Rusty Lundberg, Director, Division of Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4850 Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill - Notice Pursuant to Part I.G.I (a) Dear Mr. Lundberg: The White Mesa Mill (the "Mill") performed first quarter ("Ql") groundwater monitoring during the period from January 1, to March 31, 2015 under the August 24, 2012 version of the Mill's Groundwater Discharge Permit (the "GWDP"). All analytical data needed for comparison to the GWCLs were received during the period ending March 31, 2015. Pursuant to Part I.G.I.a) of the GWDP, (August 24, 2012) please take notice that the concentrations of specific constituents in the monitoring wells highlighted in yellow and bold italics in the columns for this quarter in the attached Table 1 exceeded their respective GWCLs. For ease of review, Table 1 has been formatted to simplify the tracking of any continued exceedances from one monitoring period to the next by charting ongoing monitoring of the same well in the same row, and by highlighting exceedances (in color and bold italics). Part I.G. 1 c) of the GWDP states "that the Permittee shall prepare and submit within 30 calendar days to the Executive Secretary a plan and a time schedule for assessment of the sources, extent and potential dispersion of the contamination, and an evaluation of potential remedial action to restore and maintain groundwater quality to ensure that Permit limits will not be exceeded at the compliance monitoring point and that DMT or BAT will be reestablished." The summary below relating to Ql 2015 exceedances includes, for each exceedance, a brief discussion of whether such a plan and schedule is or is not required or appropriate at this time in light of other actions currently being undertaken by Energy Fuels Resources (USA) Inc. ("EFRI") or in light of other reports submitted by EFRI, and as determined by Division of Radiation Control ("DRC") Staff. A description of the other actions and reports which have affected the requirement to submit a plan and time schedule are as follows: 1. Nitrate + nitrite and chloride in monitoring wells at the site have been the subject of ongoing investigations at the Mill. Based on the results of the previous investigations, EFRI and the Director acknowledge that it has not been possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and proportion(s) of the local nitrate + nitrite and chloride in groundwater. EFRI submitted a Corrective Action Plan ("CAP") in February 2012 for nitrate + nitrite and chloride in groundwater. The CAP was approved on December 12, 2012 and the activities associated with the CAP are on-going. Based on information provided by DRC in Letter to Mr. Rusty Lundberg May 6,2015 Page 2 teleconferences on April 27, and May 2, 2011, due to the ongoing activities and actions, the 30- day plan and schedule for assessment is not required for nitrate + nitrite and chloride exceedances at this time. 2. As discussed in previous quarterly groundwater sampling reports, the background levels and GWCLs for pH were established based on eight or more quarters of laboratory data, which are historically higher than field data. EFRPs letter to the Director dated January 31, 2011 proposed the recalculation of the GWCLs for field pH. Following the statistical evaluation of pH data by EFRPs geochemical consultant, INTERA, Inc., EFRI compared the Mill's groundwater pH data from Q2 2011 and noted that all of the June 2011 groundwater results, and many of the other results from Q2 2011, were already outside the revised GWCLs that were to be proposed in the June 30, 2011 letter. Pursuant to teleconferences with DRC on December 5, and December 19, 2011, EFRI submitted a Work Plan and Schedule on January 20, 2012 and a revised plan based on DRC comments on April 13, 2012. Based on the approved Work Plan and Time Schedule, EFRI and DRC entered into a Stipulated Consent Agreement ("SCA") dated July 12, 2012. The SCA required the completion of the pH Report and the Pyrite Investigation and associated report. The pH Report and Pyrite Investigation Report were submitted November 9, 2012 and December 7, 2012 respectively. By letter dated April 25, 2013, DRC accepted the conclusions that the out- of-compliance results for pH are due to background effects within the aquifer matrix and are not caused by Mill activities. DRC also approved the recalculation of the GWCLs. As a result, the 30-day plan and schedule for assessment is not required for field pH exceedances. 3. A Plan and Time Schedule will not be prepared for monitoring wells with two successive exceedances in Q3 2014 if successive exceedances were reported in a previous quarter and were included in the Source Assessment Reports ("SARs"), submitted October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13, 2014, and March 19, 2014. A Plan and Time Schedule will not be submitted for those constituents covered by the previously mentioned SARs, because the conclusions and actions delineated in those reports were either accepted by DRC as documented in DRC correspondence dated April 25, 2013, July 23, 2013, September 17, 2013 January 7, 2014, March 10, 2014, and June 5, 2014 respectively. 4. Chloroform and methylene chloride are the subject of the ongoing chloroform pumping program and are covered by State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ") Docket No. UGW-20-01. As a result, the 30-day plan and schedule for assessment of chloroform and methylene chloride exceedances is not required. It is important to note that under the GWDP, GWCLs have been determined on a well-by-well basis to reflect background groundwater quality, as defined by the mean plus second standard deviation concentration, or the equivalent. Accordingly, the GWDP requires that constituent concentrations in each monitoring well shall not exceed the GWCLs set out in Table 2 of the GWDP. It should be noted that, because the GWCLs have been set at the mean plus second standard deviation, or the equivalent, un- impacted groundwater would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to groundwater from Mill operations. In fact, more frequent sampling of a given analyte will increase the number of exceedances due to statistical variation and not due to Mill activity. Additionally, given the slow velocity of groundwater movement, accelerated sampling at a monthly frequency can result in resampling of essentially the same water and can lead to repeat Letter to Mr. Rusty Lundberg May 6,2015 Page 3 exceedances for accelerated constituents not due to Mill activities, but due to repeat sampling of the same water. 1.0 Exceedances in Required Quarterly Sampling Wells 1.1 Quarterly Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods in Ql 2015. A 30-day plan and schedule contemplated in Part I.G.I c) of the GWDP will not be required for the consecutive exceedances below for the reasons stated below. One-time exceedances and non-successive exceedances are noted on Table I, but not listed below. Consecutive exceedances which occurred in previous reporting periods are discussed in the SARs submitted to DRC October 10, 2012, May 8, 2013, August 30, 2013, December 17, 2013, January 13, 2014, and March 19, 2014 and the Plan and Time Schedule submitted December 4, 2014. MW-11 • Manganese concentrations exceeded the GWCL in MW-11 in all of the Ql 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-14 • Field pH has been slightly outside (slightly lower than) the GWCL for all of the Ql 2015 sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-25 • Field pH has been slightly outside (slightly lower than) the GWCL for all of the Ql 2015 sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Uranium concentrations exceeded the GWCL in MW-25 in the January and Ql 2015 (February) sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The Letter to Mr. Rusty Lundberg May 6,2015 Page 4 recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-26 • Nitrate + nitrite has exceeded its GWCL in the Ql 2015 and March monthly sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • Chloroform has exceeded its GWCL for all of the Ql 2015 sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of chloroform. Because this well is used in the chloroform capture program which is the subject of separate investigations and actions, a plan and time schedule to address the consecutive exceedances is not necessary and is not being submitted. • Methylene chloride has exceeded its GWCL for all of the Ql 2015 sampling events. MW-26 is used as a pumping well for the ongoing chloroform capture program and is expected to yield increased concentrations of methylene chloride. Because this well is used in the chloroform capture program which is the subject of separate investigations and actions, a plan and time schedule to address the consecutive exceedances is not necessary and is not being submitted. MW-26 Note: As stated in the September 2009 Statement of Basis (page 23) in support of the January 20, 2010 revisions to the GWDP, "[i]t should be noted that, because MW-26 is a pumping well for chloroform removal, concentrations of all constituents in that well are subject to potential variation over time as a result of the pumping activity. This will be taken into account by the Executive Secretary in determining compliance for this well." Based on information provided by DRC in teleconferences on April 27, and May 2, 2011, due to the current pumping status as part of the chloroform investigation program, the 30-day plan and schedule for assessment is not required at this time for exceedances of chloroform and methylene chloride in MW-26. • The uranium concentration exceeded its GWCL in Ql 2015 and March monthly sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL for all of the Ql 2015 sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. Letter to Mr. Rusty Lundberg May 6,2015 Page 5 • The chloride concentration exceeded its GWCL in all of the monitoring periods for Ql 2015. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-30 • Nitrate + nitrite has exceeded its GWCL in all of the Ql 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL all of the Ql 2015 sampling events. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The selenium concentration exceeded its GWCL in all of the Ql 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-31 • Nitrate + nitrite has exceeded its GWCL in all of the Ql 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The chloride concentration exceeded its GWCL in all of the monitoring periods for Ql 2015. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • The sulfate concentration exceeded its GWCL in all of the monitoring periods for Ql 2015. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. Letter to Mr. Rusty Lundberg May 6, 2015 Page 6 • The selenium concentration exceeded its GWCL in all of the monitoring periods for Ql 2015. This consecutive exceedance is addressed in the SAR, dated August 30 2013. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • The Total Dissolved Solids ("TDS") concentration exceeded its GWCL in all of the Ql 2015 sampling events. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL for all of the Ql 2015 sampling events. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. However, at the time of the November 9, 2012 and December 7, 2012 reports, the pH in MW-31 was not below the GWCLs. Due to the additional pH data available a plan and schedule for assessment will be submitted under separate cover within 30 days of this Exceedance Notice. Additional constituents in MW-31 may be assessed during the Plan and Time Schedule and SAR. It is important to note EFRI requested removal of field pH from accelerated monitoring in MW-31 by letter dated February 9, 2015. DRC approved the removal of these constituents from monthly accelerated monitoring by letter dated March 25, 2015. The sample results reported concentrations outside of the GWCLs. MW-35 • The manganese concentration exceeded the GWCL in the January monthly and Ql sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • The uranium concentration exceeded the GWCL in MW-35 in all of the Ql 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July Letter to Mr. Rusty Lundberg May 6, 2015 Page 7 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • The selenium concentration exceeded the GWCL in MW-35 in the Ql 2015 and March monthly sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • The gross alpha minus Rn and U ("gross alpha") concentration exceeded the GWCL in MW-35 in all of the Ql 2015 sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. • Field pH has been slightly outside (slightly lower than) the GWCL in the December 2014 and January 2015 monthly sampling events. A plan and schedule to address this exceedance is not necessary and is not being submitted because the exceedances are based on the interim GWCLs for MW-35, which have been set at a fraction of the Groundwater Quality Standards. Background has been established for MW-35 in the Background Report submitted to DRC on May 1, 2014. As a result of the Background Report, the GWCLs have been calculated and accepted by DRC in a letter dated July 15, 2014. The calculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the calculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. It should be noted that the exceedances of the interim GWCLs noted herein, do not necessarily represent impacts to groundwater from Mill activities. 1.2 Quarterly Wells with New Exceedances Reported in Ql No new exceedances for the quarterly wells were noted during Ql 2015. Letter to Mr. Rusty Lundberg May 6,2015 Page 8 2.0 Exceedances in Semiannual Sampling Wells Accelerated to Quarterly 2.1 Semi-annual Wells with Two Successive Exceedances As indicated in the attached Table 1, the analytes discussed below exceeded their respective GWCLs for two successive sampling periods (Q4 2014 and Ql 2015). MW-3 • Fluoride has exceeded the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Selenium has exceeded the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-3A • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-12 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the Letter to Mr. Rusty Lundberg May 6,2015 Page 9 November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Selenium has exceeded the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. As a result of the SAR, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-15 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-18 • Thallium has exceeded the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. This consecutive exceedance is addressed in the SAR, dated October 10, 2012. In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells (MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In correspondence dated April 25, 2013, DRC noted "DRC agrees with the justification provided by EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan and schedule is not necessary because the exceedance is not caused by Mill activities and was previously discussed in the October 10, 2012 SAR. Until such time as the GWCLs are removed, the exceedances will continue to be noted and reported. MW-19 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. Consecutive exceedances are also addressed in the SAR, dated October 10, 2012. In the October 10, 2012 SAR, EFRI requested the removal of GWCLs for the far upgradient wells (MW-1, MW-18, and MW-19) at the Mill which cannot be impacted by Mill activities. In correspondence dated April 25, 2013, DRC noted "DRC agrees with the justification provided by EFR, that far upgradient wells are not likely to be impacted by current Mill activities..." and has recommended the removal of GWCLs for MW-18 from the next revision of the GWDP. A plan and schedule is not necessary because the exceedance is not caused by Mill activities and was previously discussed in Letter to Mr. Rusty Lundberg May 6, 2015 Page 10 the October 10, 2012 SAR. Until such time as the GWCLs are removed, the exceedances will continue to be noted and reported. • Nitrate + nitrite has exceeded its GWCL in both the Q4 2014 sampling event and the Ql 2015 sampling events. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-24 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-27 • The chloride concentration exceeded its GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved to address nitrate+nitrite contamination which is expected to address chloride in groundwater. The actions specified in the CAP are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. MW-28 • Chloride has exceeded the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event and during previous quarters. As mentioned above, a CAP has been submitted and approved and the specified actions are currently being implemented; therefore a plan to address this consecutive exceedance is not necessary and is not being submitted. • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. MW-29 • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the Letter to Mr. Rusty Lundberg May 6,2015 Page 11 GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. • Field pH has been slightly outside (slightly lower than) the GWCL for both the Q4 2014 sampling event and the Ql 2015 sampling event. As mentioned above, site-wide pH issues and trends are addressed in reports submitted on November 9, 2012 and December 7, 2012. As a result of the November 7, 2012 report, the GWCLs have been recalculated and accepted by DRC. The recalculated GWCLs will become effective upon their publication in the next revision of the GWDP. As a result of DRC's acceptance of the recalculated GWCLs, a plan and schedule to address this consecutive exceedance is not necessary and will not be submitted. Until such time as the new GWCLs become effective, the exceedances will continue to be noted and reported. 2.1 Semi-annual Wells with New Exceedances Reported in Ql One new exceedance for the Ql 2015 semi-annual well sampling program is listed below. This exceedance will result in an accelerated sampling frequency from semi-annually to quarterly. It is important to note that the well listed below will only be sampled during the first and third quarterly events for the constituents which exceeded their GWCL. The wells listed below will be sampled for all constituents listed in the GWDP during the second and fourth quarterly events as that is the regularly scheduled sampling for the semi-annual wells. • Chloride in MW-32 was above the GWCL in the Ql sampling event. Relative to accelerated reporting requirements, based on phone conversations with UDEQ on April 5, 2010, reporting of exceedances is required to be completed within 30 days of receipt of the last data package for a quarterly monitoring event. Similarly, accelerated monitoring is required to commence the month following the submission of the Exceedance Notice for a specified quarter for wells that are being accelerated from quarterly to monthly and the quarter following the submission of the Exceedance Notice for wells that are being accelerated from semiannually to quarterly. Per teleconferences with UDEQ, EFRI proposed modified language for the GWDP, Part l.G.l on May 25, 2012, to document DRC concurrence with the accelerated reporting and monitoring agreements resulting from the April 5, 2012 teleconference. MW-32 ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David Frydenlund Harold Roberts David Turk Dan Hillsten Scott Bakken Table 1 - GVVCI, Kxceedances for First Quarter 2015 under the August 24, 2012 GWDP Ql 2010 Results Q2 2010 Results Q3 2010 Results Q4 2010 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24,2012 GWDP Ql 2010 Sample Date MW-11 (Class II) Manganese (ug/L) Ql 2010 Result Q2 2010 Sample Date Q2 2010 Result May 2010 Monthly Sample Date May 2010 Monthly Result June 2010 Monthly Sample Date June 2010 Monthly Result July 2010 Monthly Sample Date July 2010 Monthly Result August 2010 Monthly Sample Date August 2010 Monthly Result Q3 2010 Sample Date Q3 2010 Result October 2010 Monthly Sample Date October 2010 Monthly Result Q4 2010 Sample Date Q4 2010 Result Required Quarterly Sampling Wells 7/20/2010 141 133 December 2010 Monthly Sample Date December 2010 Monthly Result MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 6.45 6.29 6.45 8/25/2010 6.48 9/8/2010 6.51 10/20/2010 11/10/2010 6.37 12/15/2010 Field pH (S.l'.l 7.2 6.36 MW-25 (Class III) Cadmium (ug/L) 1.5 2/3/2010 4/28/2010 NS NS Uranium (ug/L) 5.93 NA Nitrate + Nitrite (as N) (mg/L) 0.62 1.3 0.6 0.7 Uranium (ug/L) 58.7 71.8 72.7 Chloroform (ug/l.) 1700 800 Chloride (mg/L) 58.31 MW-26 (Class III) Carbon Tetraehloride (ug/L) 4/22/2010 5/21/2010 NA Field pH (S.U.) 6.59 6.36 6.45 6.60 6.61 6.49 Dichloromcthanc (Methylene Chloride) (ug/L) 9.9 2.2 12 Nitrate + Nitrite (as N) (mg/L) 2.5 15.8 7/21/2010 Chloride (mg/L) 128 Uranium (ug/L) 8.32 6.82 NS MW-30 (Class II) 6/15/2010 Field pH (S.U.) 6.50 6.81 6.62 7.47 7/21/2010 7/27/2010 6.80 (6.82) 8/24/2010 6.73 9/14/2010 9/21/2010 6.64 6.80(6.84) 6.77 6.75 Ammonia (mg/l.) <0.05 <0.()5 NS NS Selenium (ug/L) 35.3 7/27/2010 8/24/2010 12.6 Nitrate + Nitrite (as N) (mg/L) 21.7 22.5 6/15/2010 21.1 7/21/2010 20 8/24/2010 22 21 20 20 TDS (mg/l.) MW-31 (Class I Chloride (mg/L.) 2/9/2010 4/20/2010 NS Selenium (ug/L.) 71 9/13/2010 (9/21/10) NS 11/9/2010 Field pH (S.U.) 7.38 5/21/2010 7.66 (7.13) Sulfate (mg/L.) NS 527 NS 12/14/2010 Manganese (ug/L) 200 698 Thallium (ug/l) 0.5 1.14 MW-35 (Class II) (iross Alpha minus Rn & U (pCi/I.) NS NS NS NS NS 11/30/2010 2.6 Field pH (S.U.) 6.5 - 8.5 Selenium (ug/L) 12.5 Uranium (ug/l.) 7.5 289 Required Semi-Annual Sampling Wells MW-01 (Class II) Manganese (ug/l.] Tetrahydrofuran (ug/L) Field pH (S.U.) Sulfate (mg/l.) 6.77 - 8.5 838 7.86 (6.87) 6.96 Selenium (ug/l.) 38.8 Field pH (S.U.) 6.5 - 8.5 6.14 (6.25) 6.35 MW-03 (Class I Sulfate (mg/l.) NS Nitrate + Nitrite (as N) (mg/1.) 0.73 Fluoride (Mg/L) 0.63 Field pH (S.U.) 6.23 (6.24) 6.21 MW-3A (Class III) Sulfate (mg/L) 3680 Nitrate + Nitrite (as N) (mg/L) 1.3 NA 1.2 TPS (mg/L) 5805 Selenium (ug/L) 89 94.8 MW-05 (Class II) Uranium (ug/I.) 7.5 MW-12 (Class I Selenium (ug/L) 25 4/27/2010 NS 9/20/2010 31.9 11/19/2010 27.6 Field pH (S.U.) 6.62 MW-15(ClassI Selenium (ug/L) Field pH (S.U.) 6.62 - 8.5 NS NS NS NS NS Ql 2010 Results Q2 2010 Results Q3 2010 Results Q4 2010 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP Ql Sample Date Ql Result Q2 Sample Date Q2 Result May Monthly Sample Date May Monthly Result June Monthly Sample Date June Monthly Result July Monthly Sample Date July Monthly Result August Monthly Sample Date August Monthly Result Q3 Sample Date Q3 Result October Monthly Sample Date October Monthly Result Q4 Sample Date Q4 Result December Monthly Sample Date December Monthly Result MW-18 (Class 111) Thallium (uc/1) Sulfate (mg/L) Field pH (S.U.) TDS (mg/L) 1938.9 6.25-8.5 3.73 Required Semi-Annual Sampling Wells, continued NA NA NS NS Field pH (S.U.) 6.61 (6.66) MW-19 (Class III) Gross Alpha minus Rn & V (pCi/L) 2.36 NS 9/15/2010 Nitrate + Nitrite (as N) (mg/L) MW-23 (Class III) Held pH (S.U.) 6.18 Cadmium (ug/l.) 2.5 4.28 MW-24 (Class III) Fluoride (mg/I.) Sulfate (mg/l,) 2903 NS NS 9/21/2010 Thallium (ug/L) 1.3 1.57 1.09 Field pH (S.U.) 6.5 - 8.5 5.91(5.78) Nitrate + Nitrite (as N) (mg/l.) 5.8 MW-27 (Class I Chloride (mg/l.) NA 42 Sulfate (mg/L) NS NS NS 9/14/2010 11/12/2010 TDS (mg/L) 1075 1160 Gross Alpha minus Rn & U (pCi/L) 2.4 Chloride (mg/l.j 105 108 Cadmium (ug/L) MW-28 (Class III) Uranium (ug/I.) 4.9 NS Vanadium (ug/I.) Field pH (S.U.) 5.67 5.91 5.72 TDS (mg/I.) MW-29 (Class III) Field pH (S.U.) 6.82 NS 6.17 Gross Alpha minus Rn & U (pCi/L) 3.33 4.5 2.9 MW-32 (Class III) Chloride (mg/I.) 35.39 4/20/2010 NS Field pH (S.U.) 6.4 - 8.5 6.03 GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled — i\equwcu auu Hxeeedanees are shown in yellow Values in () parentheses are the field pH measurements for the resampied analyses. Table 1 - GWCL Exceedances fur First Quarter 2015 under the August 24, 2012 GWDP Ql 2011 Results 02 2011 Results Q3 2011 Results 04 2011 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2011 Monthly Sample Date January 2011 Monthly Sample Result Ql 2011 Sample Date Ql 2011 Result March 2011 Monthly Sample Date March 2011 Monthly Result Q2 201I Sample Date Q2 2011 Result May 2011 Monthly Sample Date May 2011 Monthly Result June 2011 Monthly Sample Date June 2011 Monthly Result July 2011 Monthly Sample Date July 2011 Monthly Result Q3 2011 Sample Date Q3 2011 Result September 2011 Monthly Sample Date September 2011 Monthly Result Q4 2011 Sample Date Q4 2011 Result . NoTember 2011 Monthly Sample Date November 2011 Monthly Result December 2011 Monthly Sample Date Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 170 6/15/2011 21 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 6.37 6.22 6.37 5.83 6.4 6.23 (6.41) 6.71 (6.82) 11/9/2011 12/12/2011 MW-25 (Class III) Field pH (S.U.) Cadmium (ug/L) 1.5 2/2/2011 3/15/2011 4/4/2011 5/11/2011 6/20/2011 7/6/2011 8/3/2011 8/30/11 6.42 (6.54) 9/7/2011 10/4/2011 11/9/2011 12/12/2011 Uranium (ug/I.) 6.5 7.02 6.8 6.72 7.06 6.74 6.37 5.27 Nitrate + Nitrite (as N) (mg/L) 0.62 0.8 0.9 2.4 0.9 1.3 Uranium (ug/I.) 56.1 58.9 55.6 Chloroform (ug/I.) 70 1200 390 1900 730 300 Chloride (mg/L) 58.31 59 64 60 66 MW-26 (Class III) Carbon Tetrachloride (ug/L) <1.0 6/20/201 1 7/6/2011 <1.0 8/3/2011 8/30/11 Field pH (S.U.) 6.07 (6.58) Diehloromethane (Methylene Chloride) (ug/L) 10 20 10 7.9 8.9 Nitrate + Nitrite (as N) (mg/L) 2.5 Chloride (mg/L) 145 MW-30 (Class II) Uranium (ug/L) 8.32 Field pH (S.U.) 6.50 6.65 6.S3 5.66 10/4/2011 11/29/2011 6.96 (6.73) 5.8! Ammonia (mg/L) 0.14 <0.05 <0.05 <0.05 Selenium (ug/L) 34 34.7 34 44.4 38.3 38.7 39.7 32.4 36.8 Nitrate + Nitrite (as N) (mg/L) 19 21 22 21 20 22 22 20 21 21 21 MW-31 (Class III) TDS (mg/L) Chloride (mg/L; 143 NS 2/1/2011 5/10/2011 6/20/2011 145 148 8/2/2011 148 9/6/2011 148 10/3/2011 Selenium (ug/L) 11/8/2011 (11/29/12) 12/12/2011 NS Field pH (S.U.) 6.73 7.01 (7.34) Sulfate (mg/l.) 532 NS 538 537 541 539 552 Manganese (ug/L) 248 270 283 Thallium (ug/l) 0.5 0.52 0.57 MW-35 (Class II) Gross Alpha minus Rn & I ipfi/l i 3.75 NS 2/15/2011 2.6 NS 6/7/2011 3.7 NS 7/20/11 8/30/2011 11/8/2011 12/14/11 Field pH (S.U.I 6.5 - 8.5 6.49 6.40 6.47 6.51 Selenium (ug/L; 12.5 Uranium (ug/I.) 7.5 21.7 NA NA 18.3 22.3 20.1 Required Semi-Annual Sampling Wells MW-01 (Class II) Manganese (ug/L) Tetrahydrofuran (ug/I. Field pH (S.U.) Sulfate (mg/L) 289 6.77 - 8.5 7.06 17.67) NA NA 7.08 (7.51) Selenium (ug/L) 40.5 MW-03 (Class III) Field pH (S.U.) 6.53 (6.83 Sulfate (mg/L) 3663 3060 3470 Nitrate + Nitrite (as N) (mg/I.) 0.73 Fluoride (Mg/L) Field pH (S.U.) 6.5 (6.92) MW-03A (Class III) Sulfate (mg/I.) 3750 Nitrate + Nitrite (as N) (mg/I.) 1.3 TDS (mg/L) 5805 5«/0 Selenium (ug/I.) 89 99 95 MW-05 (Class II) Uranium (ug/L) 7.5 29.5 MW-12 (Class III) Selenium (ug/I.; 25 2/15/201 39.0 4/5/2011 8/9/201 25.4 35.4 Field pH(S.U.) 6.7 (6.97) MW-15 (Class III) Selenium (ug/l.) I 12 Field pH (S.U.) 6.62 - 8.5 Ql 2011 Results Q2 2011 Results Q3 2011 Results Q4 2011 Results Monitoring Well i Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2011 Monthly Sample Date January 2011 Monthly Sample Result Ql 2011 Sample Date Ql 2011 Result March 2011 Monthly Sample Date March 2011 Monthly Result Q2 2011 Sample Date 02 2011 Result May 2011 Monthly Sample Date May 2011 Monthly Result June 2011 Monthly Sample Date June 2011 Monthly Result July 2011 Monthly Sample Date July 2011 Monthly Result Q3 2011 Sample Date Q3 2011 Result September 2011 Monthly Sample Date September 2011 Monthly Result Q4 2011 Sample Date Q42011 Result November 2011 Monthly Sample Date November 2011 Monthly Result December 2011 Monthly Sample Date December 2011 Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/L) Field pH (S.U.) TDS (mg/I.) 1.95 3.49 3250 4/6/2011 3.74 1780 NA NA NA NS NA 8/10/2011 9/21/11 4.0 3.39 5.95 (6.30) 6.55 (6.63) 3220 Field pH (S.U.) 6.88 (7.02) MW-19 (Class III) Gross Alpha minus Rn & U (pCi/L) 2.36 2/21/2011 NS NS NS 10/12/2011 Nitrate + Nitrite (as N) (mg/l.) MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 10/6/201 6.56 (6.77) Cadmium (ug/I.; 2.5 2.78 2.61 1.78 MW-24 (Class III) Fluoride (mg/I.) Sulfate (mg/L) 2903 4/5/2011 NS 10/11/201 2500 Thallium (ug/L) 1.42 1.07 Field pH (S.U.) 6.5 - 8.5 5.73 6.12 6.45 6.44 Nitrate + Nitrite (as N) (mg/L) MW-27 (Class III) Chloride (mg/L) 38 46 43 43 Sulfate (mg/L) NS NS NS 10/5/2011 TDS (mg/L) 1075 1090 1190 1090 1110 Gross Alpha minus Rn & U (pCi/L) NS Chloride (mg/L) 109 105 Cadmium (ug/L) MW-28 (Class III) Uranium (ug/L) 2/14/2011 4/11/2011 3.29 NS NS NS 8/8/2011 10/5/2011 Vanadium (ug/L) 30 Field pH (S.U.) 6.1-8.5 5.69 5.78 (5.07(6.11) MW-29 (Class III) TDS (mg/L) Field pH (S.U.) NS 4/18/2011 NS 8/9/2011 10/5/2011 MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 3.33 1.5 4.6 3.7 Chloride (mg/l.) 35.39 NS 8/2/2011 8/30/11 10/3/2011 NS Field pH (S.U.) 6.4 - 8.5 5.99 6.14 6.10 6.35 NS NA Notes: GWCL values are taken from August 24. version of (1WDP. NS = Not Required and Not Sampled Fxeeedanees are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table I - GWCL Exceedances for First Quarter 21)15 under the August 24, 2012 GWDP Ql 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2012 Monthly Sample Date January 2012 Monthly Result Ql 2012 Sample Date Ql 2012 Result March 2012 Monthly Sample Date March 2012 Monthly Result April 2012 Monthly Sample Date April 2012 Monthly Result Q2 2012 Sample Date Q2 2012 Result June 2012 Monthly Sample Date June 2012 Monthly Result Q3 2012 Sample Date Q3 2012 Result August 2012 Monthly Sample Date August 2012 Monthly Result September 2012 Monthly Sample Date September 2012 Monthly Result October 2012 Monthly Sample Date October 2012 Monthly Result Q4 2012 Sample Date Q4 20I2 Result December 2012 Monthly Sample Date Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 2/13/2012 5/8/2012 127 161 138 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 6.36 7.08 10/23/2012 11/27/2012 6.52 Field pH (S.U.) 6.5 - 8.5 6.63 6.83 6.73 6.47 MW-25 (Class III) Cadmium (ug/L) 1.5 1/25/2012 3/14/2012 4/9/2012 5/2/2012 6/18/2012 7/10/2012 8/6/2012 9/18/2012 1.56 12/24/2012 Uranium (ug/l.) 6.6 6.93 6.52 6.4^ 6.72 Nitrate + Nitrite (as N) (mg/L) 0.62 1.9 1.2 3.4 2.9 2.3 7/11/2012 1.9 1.8 Uranium (ug/L) 64.9 56.8 Chloroform (ug/I.) 1900 3300 2900 2900 1700 2400 8/16/2012 970 Chloride (mg/L) 58.31 82 85 78 78 2.62 MW-26 (Class III) Carbon Tetrachloride (ug/L) 1/25/2012 3/14/2012 4/11/2012 5/7/2012 6/26/2012 <1.0 6/19/2012 <1.0 8/16/2012 <1.0 12/24/2012 Field pH (S.U.) 6.74 - 8.5 2/15/2012 2/21/2012 3/8/2012 6.72 (6.91) (6.71) 7.00 (7.01; 7/11/2012 8/16/2012 7.10 (6.80) 6.63 6.60 Dichloromelhanc (Methylene Chloride) (ug/L) 13 24 27 20 10 Nitrate + Nitrite (as N) (mg/L) 1/24/2012 17 18 Chloride (mg/I.) 128 139 130 135 Uranium (ug/I.; 8.38 7.84 MW-30 (Class II) 11/13/2012 12/26/2012 Field pH (S.U.) 1/24/2012 6.95 Ammonia (mg/I.) NS Selenium (ug/I.) 1/24/2012 33.3 35 39.5 39.1 37 Nitrate + Nitrite (as N) (mg/l.) 21 21 20 21.6 21 21 TDS (mg/L) 1320 1460 MW-31 (Class III) Chloride (mg/L) 150 3/13/2012 152 4/9/2012 160 5/2/2012 151 Selenium (ug/L) 6/18/2012 6/29/2012 138 7/9/2012 NA 76.9 Field pH (S.U.) 7.13 7.19 7.28 (7.63) 7.53 Sulfate (mg/L) 539 538 517 497 529 Manganese (ug/L) 200 304 273 283 253 241 Thallium (ug/l) 0.65 0.59 0.57 0.61 0.54 MW-35 (Class I Gross Alpha minus Rn & U (pCi/L) 4.1 3/13/2012 6.2 4.1 4.5 4.9 7/10/2012 Field pH (S.U.) 6.35 6.48 Selenium (ug/I.) 12.5 15.9 18.8 19.0 Uranium (ug/L) 16.1 22.2 22.5 24.5 26.2 22.9 22.4 Required Semi-Annual Sampling Wells fetrahydrofuran (ug/L MW-01 (Class II) Manganese (ug/L) Field pH (S.U.) Sulfate (mg/l.) 11.5 NS NA NA 176 21.8 846 Selenium (ug/I.) 51.1 Field pH (S.U.) 6.5 - 8.5 6.55 MW-03 (Class III) Sulfate (mg/I.) NS Nitrate + Nitrite (as N) (mg/I.) NA Fluoride (Ma/I.) 0.86 1.04 1.26 Field pH (S.U.) 6.5 - 8.5 6.35 MW-03A (Class Sulfate (mg/l.) 3640 Nitrate + Nitrite (as N) (mg/L) NS NS 5/15/2012 TDS (mg/l.) Selenium (ug/L) 99.3 MW-05 (Class II) Uranium (ug/L) 7.5 NS MW-12 (Class III) Selenium (ug/I.) 2/29/2012 7/17/2012 23.0 Field pH (S.U.) 6.5 - 8.5 MW-15 (Class III) Selenium (ug/I.) Field pH (S.U.) 2/22/201 NS NS 11/14/2012 NS — 1— Ql 2012 Results Q2 2012 Results Q3 2012 Results Q4 2012 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2012 Monthly Sample Date January 2012 Monthly Result Ql 2012 Sample Date Ql 2012 Result March 2012 Monthly Sample Date March 2012 Monthly Result April 2012 Monthly Sample Date April 2012 Monthly Result Q2 2012 Sample Date Q2 2012 Result June 2012 Monthly Sample Date June 2012 Monthly Result Q3 2012 Sample Date Q3 2012 Result August 2012 Monthly Sample Date August 2012 Monthly Result September 2012 Monthly Sample Date September 2012 Monthly Result October 2012 Monthly Sample Date October 2012 Monthly Result Q4 2012 Sample Date Q4 2012 Result December 2012 Monthly Sample Date December 2012 Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/L) Held pH (S.U.) TDS (mg/L) 3198.77 3230 3.S1 3280 3220 11/26/2012 3160 NS NA Field pH (S.U.) MW-19 (Class III) (iross Alpha minus Rn & U (pCi/I.) 2.36 NS Nitrate + Nitrite (as N) (mg/l.) 2.83 3.9 3.7 3.96 MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 Cadmium (ug/I.) 2.5 2.25 2.01 MW-24 (Class III) Fluoride (mg/I.) 0.36 0.55* Sulfate (mg/I.) NS NS 7/18/2012 Thallium (ug/l.) 1.36 Held pll IS.1M 6.03 6.21 Nitrate + Nitrite (as N)(mg/1.) 6.9 MW-27 (Class III) Chloride (mg/I.) *8 46 47 Sulfate (mg/L) 2/28/2012 NS 5/1/2012 NS TDS (mg/L) 1075 Gross Alpha minus Rn & U (pCi/L) 2.3 010)2012 Chloride (mg/L) Cadmium (ug/L) 5.2 4.37 MW-28 (Class III) Uranium (ug/I.) NS Vanadium (ug/I.) 30 <15.0 Field pH (S.U.) 6.1-8.5 7/16/2012 8/1/2012 6.38 (1311 TDS (mg/L) 4600 4430 MW-29 (Class III) Field pH (S.U.) 7/16/2012 8/1/2012 6.68 (6.45) Gross Alpha minus Rn & U (pCi/L) 3.33 MW-32 (Class III) Chloride (mg/L) NS 2/21/2012 NS Field pH (S.U.) 6.4 - 8.5 6.40 6.72 Notes: GWCL values are taken from August 24. 2012 version of GWDP. NS = Not Required and Not Sampled — isequueu tuiu Exceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table 1 - GWCL Exceedances for First Quarter 2015 under the August 24, 2012 GWDP Ql 2013 Results 02 2013 Results Q3 2013 Results Q4 2013 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24 2012 GWDP January 2013 Monthly Sample Date January 2013 Monthly Result Ql2013 Sample Date Ql 2013 Result March 2013 Monthly Sample Date March 2013 Monthly April 2013 Monthly Sample Date April 2013 Monthly Result Q2 2013 Sample Date Q2 2013 Result June 2013 Monthly Sample Date June 2013 Monthly Result Q3 2013 Sample Date Q3 2013 Result August 2013 Monthly Sample Date August 2013 Monthly Result September 2013 Monthly Sample Date September 2013 Monthly Result October 2013 Monthly Sample Date October 2013 Monthly Result Q4 2013 Sample Date Q4 2013 Result December 2013 Monthly Sample Date December 2013 Monthly Result Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 131.29 1/23/2013 2/211/2(113 139 3/20/2013 4/16/2013 5/14/2013 144 6/25/2013 /52 MW-14 (Class III) Field pH (S.U.) 6.47 6.48 6.77 11/20/2013 6.51 12/18/2013 MW-25 (Class III) Field pH (S.U.) 6.5 - 8.5 6.65 6.62 7.0(1 Cadmium (ug/l.) 3/19/2013 4/17/2013 5/14/2013 6/24/201 ) 7/10/2013 8/19/2013 1.57 9/17/2013 11/19/2013 Uranium (ug/L) 5.94 Nitrate + Nitrite (as N) (mg/L) 2.01 3.04 2.11* 1.98 1.77 3.60 4.10 1.38 Uranium (ug/l.) 58.8 75.8 Chloroform (ug/I.) 70 1270 1500 1340 1680 1210 4030* 2410 Chloride (mg/L) 63.1 87.8 77.9* 72.1 70.8 63.8 MW-26 (Class III) Carbon Tetrachloride (ug/L) 1/24/2013 2/20/2013 3.15 3/20/2013 4/17/2013 5/23/2013 <1.0 6/5/2013 6/25/2013 <1.0 7/11/2013 <1.0 8/20/2013 Field pH (S.U.) 6.71 Diehloromethane (Methylene Chloride) (ug/l.) 6.49 5.53 8.31 10.2 52.4* [12.1] 14.2 Nitrate + Nitrite (as N) (mg/I.) 2.5 19.2 21.4 14.3 16.8 18.8 Chloride (mg/I.) 130 131 128 MW-30 (Class II) Uranium (ug/I.) 8.32 8.36 7.08 7.48 7.07 Field pH(S.U.) 6.50 6.78 6.96 Ammonia (mg/I.) 0.14 Selenium (ug/I.) 34 37.2 42.3 39 37.3 39.4 36.5 Nitrate + Nitrite (as N) (mg/l.) 22.8 19.3 18.8 23.8 20.0 21.7 16.0 MW-31 (Class III) TDS (mg/I.) 1500 1460 Chloride (mg/L) 143 1/22/2013 176 3/19/2013 168 171 5/13/2013 169 8/19/2013 9/17/2013 Selenium (ug/L) 73.7 73.2 72.6 80.7 74.5 Field pH (S.U.) 6.37 7.92 Sulfate (mg/L) 532 644 611 668 630 659 659 Manganese (ug/L) 243 250 262 257 240 251 Thallium (ug/l) 0.715 0.946 <0.5 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 3.75 1/23/2013 6.62 2/26/2013 5.09 9.51 4.75 4.92 3.24 7/9/2013 5.70 3.92 10/23/2013 3.73 Field pH (S.U.) 6.5 - 8.5 6.83 6.52 Selenium (ug/L) 13.6 19.8 Uranium (ug/L) 23.6 22.0 19.3 23.0 21.4 20.2 21.8 24.1 Required Semi-Annual Sampling Wells MW-01 (Class Manganese (ug/L) Tetrahydrofuran (ug/L) Field pH (S.U.) Sulfate (mg/l.) 6.77 - 8.5 27 3.26 930 Selenium (ug/I.) 52.0 MW-03 (Class III) Field pH (S.U.) Sulfate (mg/I.) 3663 Nitrate + Nitrite (as N) (mg/l.) 0.73 Fluoride (Mg/I.) 0.902 0.994 Field pH (S.U.) MW-03A (Clas: III) Sulfate (mg/L) Nitrate + Nitrite (as N) (mg/L) 1.3 NS 5/23/2013 TDS (mg/L) 5805 5750 6020 5860 Selenium (ug/L.) MW-05 (Class 11) Uranium (ug/L) 36 20.1 MW-12 (Class Selenium (ug/I.) 25 3/6/2013 NS 7/17/2013 NA Field pH (S.U.) MW-15 (Class III) Selenium (ug/L) Field pH (S.U.) 6.62 - 8.5 NS NS 1/20/2013 Ql 2013 Results Q2 2013 Results Q3 2013 Results Q4 2013 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2013 Monthly Sample Date January 2013 Monthly Result Ql 2013 Sample Date Ql 2013 Result March 2013 Monthly Sample Date March 2013 Monthly Result April 2013 Monthly Sample Date April 2013 Monthly Result Q2 2013 Sample Date Q2 2013 Result June 2013 Monthly Sample Date June 2013 Monthly Result Q3 2013 Sample Date Q3 2013 Result August 2013 Monthly Sample Date August 2013 Monthly Result September 2013 Monthly Sample Date September 2013 Monthly Result October 2013 Monthly Sample Date October 2013 Monthly Result Q4 2013 Sample Date Q4 2013 Result December 2013 Monthly Sample Date December 2013 Monthly Result Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/I.) Field pH (S.U.) TDS (mg/L) 1938.9 6.25-8.5 NA 2/25/2013 3.26 NA 2.81 I860 3.32 NA 3.06 3240 Field pH (S.U.) 6.58 MW-19 (Class mi Gross Alpha minus Rn & U (pCi/L) 2.36 NS 3/13/2013 NS NS 5/20/2013 NS 7/15/2013 NS Nitrate + Nitrite (as N) (mg/L) 3.70 MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 6.37 NS NS Cadmium (ug/L) 2.5 6.72 1.15 MW-24 (Class III) Fluoride (mg/L) Sulfate (mg/l.) 2903 NS 3/13/2013 5/22/2(11 1 2070 NS 7/19/2013 12/12/2013 2490 Thallium (ug/L) 1.64 Field pHlS.U.) 6.5 - 8.5 6.29 5.80 NA 6.08 Nitrate + Nitrite (as N) (mg/L) 5.6 7.94 MW-27 (Class III) Chloride (mg/L) 44.3 44.2 45.0 Sulfate (mg/L) NS 2/25/2013 NS NS NS NS TDS (mg/L) 1075 1140 1110 1110 1100 Gross Alpha minus Rn &. U (pCi/l.) Chloride (mg/l.) 105 110 Cadmium (ug/L) MW-28 (Class III) Uranium (ug/l.) NS 3/5/2013 NS 5/15/2013 7/17/2013 NS Vanadium (ug/I.) Field pH (S.U.) 5.97 6.10 MW-29 (Class HI) TDS (mg/L) Field pH (S.U.) NS 3/6/2013 5/23/2013 NS 7/17/2013 MW-32 (Class III) (iross Alpha minus Rn & U (pCi/L) 3.33 5.02 3.72 6.46 Chloride (mg/L) 35.39 NS NS 11/18/2013 Field pH (S.U.) 6.4 - 8.5 6.39 6.29 GWCL values are taken from August 24. 2012 version of GWDP. NS = Not Required and Not Sampled isi\ — ivcquncu Exceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. Table I - GWCL Kxceedances for First Quarter 2015 under the August 24, 2012 GWDP Ql 2014 Results Q2 2014 Results Q3 2014 Results Q4 2014 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24,2012 GWDP January 2014 Monthly Sample Date January 2014 Monthly Result February 2014 Monthly Sample Date February 2014 Monthly Result Ql2014 Sample Date Ql 2014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly Sample Date May 2014 Monthly Result Q2 2014 Sample Date Q2 2014 Result July 2014 Monthly Sample Date July 2014 Monthly Result August 2014 Monthly Sample Date August 2014 Monthly Result Q3 2014 Sample Date Q3 2014 Result October 2014 Monthly Sample Date October 2014 Monthly Result Q4 2014 Sample Date Q4 2014 Result December 2014 Monthly Sample Date December 2014 Monthly Result Required Quarterly Sampling Wells MW-11 (Class II) Manganese (ug/L) 131.29 141 163 134 4/25/2014 5/14/2014 128 673/2014 1S7 MW-14 (Class III) Field pH (S.U.) 6.5 - 8.5 1/8/2014 2/24/2014 6.44 6.41 6.46 6.25 MW-25 (Class III) Field pH (S.U.) 6.5 - 8.5 6.37 6.10 6.27 7.18 Cadmium (ug/L) 1.5 1.29 6/2/2014 7/28/2014 8/18/2014 9/3/2014 10/6/2014 1.57 12/9/2014 Uranium (ug/I.) 10.6 7.43 5.9 Nitrate + Nitrite (as N) (mg/L) 0,62 1.64 1.42 2.0 1.00 1.10 0.704 1.09 Uranium (ug/l. 41.8 81.7 48.4 75.4 66.0 Chloroform (ug/L) 2800 1310 1580 1450 2330 Chloride (mg/L) 58.31 61.0 80.0 59.0 68.0 MW-26 (Class III) Carbon Tetrachloride (ug/L) 6.86 5/14/2014 7/29/2014 12/10/14 12/15/14 Field pH (S.U.) 6.74 - 8.5 6.67 6.09 Dichloromethane (Methylene Chloride) (ug/L) /5.5 5.54 10.2 6.73 9.6 43.3 3.78 Nitrate + Nitrite (as N) (mg/l.) 20.3 18.4 21.3 18.3 17.9 19.4 Chloride (mg/I.) 128 139 136 136 154 MW-30 (Class II) Uranium (ug/I.) 9.82 1/8/2014 2/25/2014 3/11/2014 4/23/2014 Field pH (S.U.) 6.76 7.51 6.82 6.92 Ammonia (mg/I.) Selenium (ug/L) 35.6 35.8 38.0 37.0 35.4 42.9 Nitrate + Nitrite (as N) (mg/L) 23.3 23.1 19.0 15.2 18.9 TDS (mg/L) 1320 1510 1460 1420 1520 MW-31 (Class Chloride (mg/L) 230 230 200 173 7/28/2014 8/18/2014 12/9/2014 Selenium (ug/L) 77.9 82.8 81.5 78.9 73.0 Field pH (S.U.) 6.5 - 8.5 6.45 8.23 Sulfate (mg/L) 5J« 681 639 Manganese (ug/L) 202 228 222 Thallium (ug/l) 0.6 MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 4.12 3.98 3.36 7/29/2014 8/20/2014 Field pH (S.U.) Selenium (uti/I.) 13.9 13.2 28.9 31.4 15.5 Uranium (ug/L) 26.9 26.5 20.3 23.6 23.9 19.6 MW-01 (Class II) Manganese (ug/L) Tetrahydrofuran (ug/I. Field pH (S.U.) Sulfate (mg/l.; 838 NA 3.25 836 Required Semi-Annual Sampling Wells NA 6.75 920 Selenium (ug/I.) 94.0 62.4 MW-03 (Class III) Field pH (S.U.) 6.5 - 8.5 6.23 6.13 6.37 Sulfate (mg/I.) 3663 3800 Nitrate + Nitrite (as N) (mg/I.) 0.330 Fluoride (Mg/L) 0.68 0.77/ Field pH (S.U.) 6.5 - 8.5 6.40 6.41 MW-03A (Class III) Sulfate (mg/I.) 3640 3770 Nitrate + Nitrite (as N) (mg/L) 1.3 NS NS NS TDS (mg/L) Selenium (ug/L) 104 MW-05 (Class ID Uranium (ug/l.) 36.20 MW-12 (Class Selenium (ug/L) Field pH (S.U.) NS NS 6/4/2014 6.5 - 8.5 6.13 6.25 MW-15 (Class III) Selenium (ug/I.) 128.7 Field pH (S.U.) NS 9/2/2014 Ql 2014 Results Q2 2014 Results Q3 2014 Results Q4 2014 Results Monitoring Weil (Water Class) Constituent Exceeding GWCL GWCL in Current GWDP January 2014 Monthly Sample Date January 2014 Monthly Result February 2014 Monthly Sample Date February 2014 Monthly Result Ql 2014 Sample Date 012014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly- Sample Date May 2014 Monthly Result Q2 2014 Sample Date Q2 2014 Result April 2014 Monthly Sample Date April 2014 Monthly Result May 2014 Monthly Sample Date May 2014 Monthly Result Q3 2014 Sample Date Q3 2014 Result October 2014 Monthly Sample Date October 2014 Monthly Result Q4 2014 Sample Date Q4 2014 Result December 2014 Monthly Sample Date Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ug/l) Sulfate (mg/l.) Held pH (S.U.) TDS (mg/L) 1.95 1938.9 6.25-8.5 NA 2/19/2014 2.77 1650 6.16 NS NS 2.42 2020 3260 NA NS Field pH (S.U.) 6.46 MW-19(Clas: III) Gross Alpha minus Rn & U (pCi/L) 2.36 NS 2/18/2014 NS NA <1.0 Nitrate + Nitrite (as N) (mg/L) 2.0/ MW-23 (Class III) Field pH (S.U.) 6.5 - 8.5 6/11/2014 NA Cadmium (ug/L) 2.5 5.92 NA 2.91 NA MW-24 (Class III) Fluoride (mg/L) Sulfate (mg/L) 2903 NS NS 3/6/2014 5/30/2014 NS Thallium (ug/L) 1.23 Field pH (S.U.) 6.5 - 8.5 5.89 6.07 Nitrate + Nitrite (as N) (mg/L) 5.6 7.9S MW-27 (Class III) Chloride (mg/L) 45.9 46.0 42.6 Sulfate (mg/I.) NS NS 5/28/2014 NS NS TDS (mg/I.) 1075 1020 Gross Alpha minus Rn & u (pan.) Chloride (mg/I.) 105 113 114 Cadmium (ug/I.) 5.41 MW-28 (Class III) Uranium (ug/l.) NS 2/26/2014 NS Vanadium (ug/I.', 30 109 Field pH (S.U.) 5.72 MW-29 (Class Ill) TDS (mg/L) 4500 Field pH (S.U.) NS 2/25/2014 6.78 NS NS 6.10 MW-32 (Class III) Gross Alpha minus Rn & U (pCi/L) 3.33 4.35 Chloride (mg/I.) 35.39 Field pH (S.U.) 6.4 - 8.5 GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Exceedances are shown in yellow Values in () parentheses are the field pH measurements lor the rcsamplcd analyses. Table I - GWCL Exceedances for First Quarter 21)15 under the August 24. 2012 GWDP | Ql 2015 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, January 2015 Monthly Sample Date January 2015 Monthly Result Ql 2015 Sample Date Ql 2015 Result March 2015 Monthly Sample Date March 2015 Monthly Result Required Quarterly Sampling Wells MW-11 (Clas II) Manganese (ug/L) 1/21/2015 177 2/3/2015 MW-14 (Class III) Field pH (S.U.) 6.49 3/5/2015 6.05 MW-25 (Class III) Field pH (S.U.) Cadmium (ug/L) 1/20/2015 Uranium (ug/l.) 6.54 6.81 6.43 Nitrate + Nitrite (as N) 0ng/L) 0.965 Uranium (ug/l.) 41.8 72.6 Chloroform (ug/l.; 70 3570 1190 1020 Chloride (mg/L) 59.9 MW-26 (Class III) Carbon Tetrachloride (ug/L) 1/21/2015 2/11/2015 3/4/2015 Field pH (S.U.) Dichloromethane (Methylene Chloride) (ug/l.) 6.42 5.89 <1.0 : 6.95 Nitrate + Nitrite (as N) (mg/L) 2.5 14.9 Chloride (mg/I.) MW-30 (Class Hi Uranium (ug/I.) 3/3/2015 Field pH (S.U.) 6.50 6.41 Ammonia (mg/I.) 0.14 NS Selenium (ue/I.; 34 37.2 40.9 6.32 Nitrate + Nitrite (as N) (mg/l.) 20.9 18.7 MW-31 (Class III) TDS (mg/l.) Chloride (mg/L) 143 1/20/2015 211 3/3/2015 Selenium (ug/L) 75.6 Field pH(S.U.) Sulfate (mg/L) 532 623 19.8 Manganese (ug/L) 228 Thallium (ug/l) MW-35 (Class II) Gross Alpha minus Rn & U (pCi/L) 3.75 1/20/2015 5.61 3/4/2015 Field pH (S.U.) 6.22 Selenium (ug/L) Uranium (ug/L; 21.8 3.81 6.26 Required Semi-Annual Sampling Wells MW-01 (Class II) Manganese (ug/L) Tetrahydrofuran (ug/L) Field pH (S.U.) Sulfate (mg/l.; 6.77 - 8.5 6.66 Selenium (ug/I.) MW-03 (Class III) Field pH (S.U.) Sulfate (mg/I.) 3663 NS Nitrate + Nitrite (as N) Ortg/L) 0.73 Fluoride (Mg/I.) 1.08 Field pH (S.U.) MW-03A (Class III) Sulfalc i mg/l i Nitrate + Nitrite (as N) (mg/L) TDS (mg/I.) 5805 Selenium (ug/L) 8') 94.1 MW-05 (Clas 11) Uranium (ug/L) MW-12 (Class Selenium (ug/l.; 25 2/9/2015 30.0 Field pH (S.U.) 6.5 - 8.5 6.33 MW-15 (Class Selenium (ug/L) Field pH (S.U.) 6.62 - 8.5 NS 6.50 NS Ql 2015 Results Monitoring Well (Water Class) Constituent Exceeding GWCL GWCL in August 24, 2012 GWDP January 2015 Monthly Sample Date January 2015 Monthly Result Ql2015 Sample Date Ql 2015 Result March 2015 Monthly Sample Date March 2015 Monthly Sample Frequency Required Semi-Annual Sampling Wells, continued MW-18 (Class III) Thallium (ue/1) Sulfate (mg/L) Field pH (S.U.) TDS (mg/L) 1938.9 6.25-8.5 3198.77 3240 Semi-Annually Scmi-Annually Semi-Annually Semi-Annually Field pH (S.U.) 6.78-8.5 MW-19 (Class III) Gross Alpha minus Rn & U (pCi/L) 0.312 Nitrate + Nitrite (as N) (mg/L) 2.xl Semi-Annually Semi-Annually Semi-Annually MW-23 (Class III) Field pH (S.U.) Semi-Annually Cadmium (ug/l.) MW-24 (Class III) Fluoride (mg/I.) 0.36 0.397 Sulfate (mg/L) Thallium (ug/L) 1.27 Field pH(S.U.) Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually Nitrate + Nitrite (a (mg/L) N) MW-27 (Class III) Chloride (mg/l.) 38 44.2 Sulfate (mg/L) NS TDS (mg/L) 996 Gross Alpha minus Rn & U (pCi/I.) Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually Chloride (mg/l.) Cadmium (ug/l.; 5.2 MW-28 (Class III) Uranium (ug/l.) Vanadium (ug/I.) Field pH (S.U.) Semi-Annually Semi-Annually Semi-Annually Semi-Annually Semi-Annually MW-29 (Class III) TDS (mg/l.) 4400 4430 Field pH (S.U.) 6.46 - 8.5 6.42 Semi-Annually Semi-Annually MW-32 (Clas III) Gross Alpha minus Rn & U (pCi/L) 2.19 Chloride (mg/L) Field pH (S.U.) 2/9/2015 Semi-Annually Semi-Annually Semi-Annually GWCL values are taken from August 24, 2012 version of GWDP. NS = Not Required and Not Sampled NR = Required and Not Reported NA = Not Applicable Exceedances are shown in yellow Values in () parentheses are the field pH measurements for the resampled analyses. gOBBBMBStSKSKBBBBBBBSB Pursuant to the DRC letter of March 25, 2015, these constituents will no longer be monitored on an accelerated schedule. These constituents will be dropped from this re after this quarter. I